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Why this is a general recommendation, not personal advice

Everything Volum Invest AS publishes (the signals, the scores, the rankings, the alerts) is a general investment recommendation under Article 20 of the EU Market Abuse Regulation (MAR). It is not investment advice. This page explains what that distinction means in law, why the service falls on the general side of it, and what that means for you as a subscriber.

The Disclaimer and the Conflicts of Interest disclosure state the conclusion. This page shows the working.

The short version

Every subscriber on a given tier sees the same signal, for the same instrument, at the same time, produced by the same computation from the same public market data. Nothing about you (your holdings, your goals, your finances, your risk appetite) enters that computation, because the model has no way of knowing who is looking at it. A recommendation that is the same for everyone and that considers no one's circumstances is, by definition, general.

The two categories the law draws

European securities law separates two things that can look alike on the page.

An investment recommendation (MAR Article 20; Article 3(1)(35) MAR) is information recommending or suggesting an investment strategy concerning one or more financial instruments, including any opinion as to their present or future value or price, that is intended for distribution channels or for the public. Anyone producing such recommendations must identify themselves, disclose their methodology, and disclose their conflicts of interest (Commission Delegated Regulation (EU) 2016/958). Volum Invest AS does all three: see the Conflicts of Interest disclosure, the Methodology page and the dated Holdings list.

Investment advice (MiFID II) is the provision of a personal recommendation. Commission Delegated Regulation (EU) 2017/565, Article 9, defines a personal recommendation as one made to a person in their capacity as an investor that is presented as suitable for that person, or is based on a consideration of that person's circumstances. It also provides that a recommendation is not personal if it is issued exclusively to the public. In Norway, giving investment advice is investeringsrådgivning under verdipapirhandelloven § 2-1, an activity that requires authorisation from Finanstilsynet. Volum Invest AS holds no such authorisation and does not provide that service.

The line between the two is therefore not about what a recommendation says. A buy signal on a particular share is a general recommendation if the same signal reaches everyone by the same rule, and a personal one if it was chosen or presented for you because of who you are. The line is about how the recommendation is produced and for whom.

Why the signals are general

Each of the following is a description of how the service is actually built, not a policy statement.

1. One model, one run, one output

The signal is a single composite score per instrument, computed by ranking every instrument in the universe against every other on the same day. There is one such computation per refresh, approximately every 15 minutes during the trading day, and it produces one score, one ranking and one buy / sell / trim label per instrument. Those are what every page shows. There is no per-user model, no per-user parameter, and no per-user run.

2. Nothing about you enters the model

The inputs are market data: price, trading volume, realised volatility, the VIX volatility index and the level of a broad market index, from public data providers. No field describing a subscriber (holdings, watchlist, tier, account, location, history on the site) is an input to the score. The model cannot consider your circumstances because it never receives them.

3. No discretion

Signals are generated by algorithm. No person selects, adjusts, suppresses or promotes an individual signal, for any subscriber or for the public.

4. It is published to the public

The full signal history since the record's fixed start date (1 January 2025), every entry and exit under the current rules, including the losing ones, is published at /episodes. The methodology, the conflicts disclosure and the holdings list are public pages. The recommendations are made to the public, which is the condition MAR attaches to a general recommendation and the condition that keeps a recommendation from being personal under Delegated Regulation 2017/565.

5. Subscription tiers slice the same list; they do not choose for you

Starter shows the top 20 instruments by the model's own score, Pro the top 100, Max the entire universe. The cut is made by the model's ranking, the same ranking for everyone, and it is identical for every subscriber on a given tier. What differs between tiers is how much of one universal output you can see, never which instruments are chosen for you. Two Pro subscribers who open the site at the same moment see the same 100 names with the same scores.

One refinement should be stated plainly. An instrument you have added to your own watchlist or portfolio stays visible to you even if its score falls outside your tier's top-N. That is an access rule, set by you when you added the name, and the score and label you see for it are byte-for-byte what a Max subscriber sees. It changes which rows you can read, not what the recommendation is.

6. Portfolio and watchlist tools measure; they do not select

Subscribers on Pro and Max can enter a portfolio and a watchlist. The tools that operate on those lists (pairwise and portfolio correlations, concentration warnings, beta, realised volatility, currency exposure, overlap between a watchlist name and holdings) return measurements about instruments you chose. They tell you what the relationship is between things already on your list. They never propose an instrument to you because of what you hold, rank the universe against your book, or filter the signals by it.

That is the boundary the service is built around: a column you can sort is a tool; a list of names to add is advice. The first is general. The second would be a personal recommendation.

7. Alerts: the signal is universal, only the delivery is yours

If you turn on alerts, you are told when a signal changes on an instrument that is on one of your lists. The signal that triggers the alert is the same signal published to every subscriber; the only personal element is that your lists decide which of those universal signals is delivered to you. Every alert says so in its own text: "You are receiving this because the ticker is on one of your lists; the signal itself is published to all subscribers and is not tailored to you or your circumstances." That sentence is load-bearing, and it is checked by an automated test before any alert can be sent.

8. Changes to the model reach everyone at once

When the rules that generate the signals are changed, the change applies to every subscriber from the same moment and is disclosed. There is no version of the model that any one subscriber receives and another does not. What a model change does to the published performance figures (the recomputation of the backtested history under the new rules, and the treatment of the live track record) is set out in the Disclaimer's section on why published figures change, which is the authoritative statement of it.

What this means for you

Because nothing about you enters the service, the service cannot tell you whether any signal is suitable for you. It does not know your financial situation, your objectives, your time horizon, your tax position, your existing exposures, or how much of a loss you can bear. How much to invest, whether to act on a signal at all, how to size a position, and how to diversify are your decisions. If you want a recommendation that takes your circumstances into account, that is investment advice, and you should obtain it from an adviser authorised by Finanstilsynet or the equivalent authority in your jurisdiction.

What you can rely on is that you receive the same information as every other subscriber on your tier, at the same time; that the method behind it is published; that the conflicts of interest and holdings of the people producing it are disclosed; and that the full track record, including the losses, is public.

How this is kept true

The general / personal boundary is treated as a design constraint, not a disclaimer. It is enforced in the application code and pinned by automated tests: one that fails if any per-subscriber tool returns a ranked list of instruments, one that fails if an alert goes out without the sentence quoted above, and one that fails if a whole-universe page publishes a score outside a subscriber's tier. Any new feature that would select, rank or filter instruments per subscriber requires legal review before it is released. The Conflicts of Interest disclosure is updated whenever a position is opened or closed, rather than on a fixed review interval.

Related pages

This page describes the service as built and the legal framework it operates under. It is not legal advice and, like every document in this section, is subject to review by a Norwegian securities-law attorney.

Last updated: 2026-09-15